On April 19, 2019, the IRS issued Revenue Procedure 2019-19 (Rev. Proc. 2019-19), which modifies the Employee Plans Compliance Resolution System (EPCRS) by expanding the use of the Self-Correction Program (SCP) to include documentary errors and certain plan loan failures. The guidance also provides an additional method of correcting operational failures by plan amendment under SCP.
EPCRS was established to allow employers sponsoring qualified retirement plans to correct errors that could adversely impact the tax-favorable status of such plans. EPCRS consists of three correction programs:
Rev. Proc. 2019-19 Changes to EPCRS
Rev. Proc. 2019-19 provides additional circumstances in which corrections under SCP may apply, including:
In addition, certain operational failures may be corrected by plan amendment under SCP if such plan amendment would result in an increase of a benefit, right or feature that is available to all employees.
The expansion of the ability to use SCP to correct certain additional plan failures should facilitate compliance, while reducing the costs and burdens associated with plan compliance.